Filed: Dec. 15, 2014
Latest Update: Dec. 15, 2014
Summary: STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE TROY L. NUNLEY, District Judge. STIPULATION Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jill Thomas, and defendant, Angela Shavlovsky, by and through her counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, December 18, 2014 at 9:30 a.m., in the above-captioned matter, and to continue the status conference to January 22, 2015 at 9:30 a.m. in the cour
Summary: STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE TROY L. NUNLEY, District Judge. STIPULATION Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jill Thomas, and defendant, Angela Shavlovsky, by and through her counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, December 18, 2014 at 9:30 a.m., in the above-captioned matter, and to continue the status conference to January 22, 2015 at 9:30 a.m. in the court..
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STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE
TROY L. NUNLEY, District Judge.
STIPULATION
Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jill Thomas, and defendant, Angela Shavlovsky, by and through her counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, December 18, 2014 at 9:30 a.m., in the above-captioned matter, and to continue the status conference to January 22, 2015 at 9:30 a.m. in the courtroom of the Honorable Troy L. Nunley.
The reason for this request is that additional time is needed by Ms. Radekin to complete review of discovery, for investigation, and for other defense preparation. In the last 30 days the government has provided additional discovery so that discovery now ends at page number 68720. The Court is advised that Ms. Thomas concurs with this request and has authorized Ms. Radekin to sign this stipulation on her behalf.
The parties further agree and stipulate that the time period from the filing of this stipulation until January 22, 2015 should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv), and Local Code T4, to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.
Accordingly, the parties respectfully request the Court adopt this proposed stipulation.
IT IS SO STIPULATED.
Dated: December 12, 2014 BENJAMIN WAGNER
United States Attorney
By: /s/ JILL THOMAS
JILL THOMAS
Assistant United States Attorney.
ORDER
For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference date of December 18, 2014 at 9:30 a.m. is VACATED and the above-captioned matter is set for status conference on January 22, 2015 at 9:30 a.m. The Court finds excludable time in this matter through January 22, 2015 under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow reasonable time necessary for effective defense preparation. For the reasons stipulated by the parties, the Court finds that the interest of justice served by granting the request outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §§ 3161(h)(7)(A), (h)(7)(B)(iv).
IT IS SO ORDERED.
